mirror-epstein-docs/results/IMAGES007/DOJ-OGR-00019602.json

{
  "document_metadata": {
    "page_number": "11",
    "document_number": "69",
    "date": "09/28/2020",
    "document_type": "Court Document",
    "has_handwriting": false,
    "has_stamps": false
  },
  "full_text": "Case 20-3061, Document 69, 09/28/2020, 2940206, Page11 of 15\nDistrict Court in the criminal case.\" Doc. 37, p 17 (emphasis in original). That is not so.\nIn the civil appeal, Ms. Maxwell is not asking this Court to rule on the propriety of the government's conduct in circumventing Martindell. Rather, Ms. Maxwell's argument in the civil appeal is that, unless this Court reverses Judge Preska's order unsealing the deposition material, Ms. Maxwell may never be able to challenge before Judge Nathan the government's conduct in obtaining her depositions. As Ms. Maxwell said in her opening brief in the appeal of Judge Preska's unsealing order:\nThe civil case is not the appropriate forum to litigate the government's apparent violation of Martindell. Ms. Maxwell intends to make that argument to Judge Nathan in the criminal case. But if Judge Preska's unsealing order is affirmed and Ms. Maxwell's deposition is released, her ability to make that argument before Judge Nathan will be prejudiced. Keeping the deposition material sealed will preserve the status quo and protect Ms. Maxwell's right to litigate Martindell and the Fifth Amendment in the criminal proceeding.\nGiuffre v. Maxwell, No. 20-2413, ECF Dkt. 69, p 33. Only by mischaracterizing\nMs. Maxwell's argument can the government contend that she \"seeks to have this Court reach the merits of her arguments on [the Martindell] issue in the context of the civil appeal, and before they have been properly litigated before and adjudicated by the District Court in the criminal case.\" See Doc. 37, p 17. Ms. Maxwell's point\n10\nDOJ-OGR-00019602",
  "text_blocks": [
    {
      "type": "printed",
      "content": "Case 20-3061, Document 69, 09/28/2020, 2940206, Page11 of 15",
      "position": "header"
    },
    {
      "type": "printed",
      "content": "District Court in the criminal case.\" Doc. 37, p 17 (emphasis in original). That is not so.\nIn the civil appeal, Ms. Maxwell is not asking this Court to rule on the propriety of the government's conduct in circumventing Martindell. Rather, Ms. Maxwell's argument in the civil appeal is that, unless this Court reverses Judge Preska's order unsealing the deposition material, Ms. Maxwell may never be able to challenge before Judge Nathan the government's conduct in obtaining her depositions. As Ms. Maxwell said in her opening brief in the appeal of Judge Preska's unsealing order:\nThe civil case is not the appropriate forum to litigate the government's apparent violation of Martindell. Ms. Maxwell intends to make that argument to Judge Nathan in the criminal case. But if Judge Preska's unsealing order is affirmed and Ms. Maxwell's deposition is released, her ability to make that argument before Judge Nathan will be prejudiced. Keeping the deposition material sealed will preserve the status quo and protect Ms. Maxwell's right to litigate Martindell and the Fifth Amendment in the criminal proceeding.\nGiuffre v. Maxwell, No. 20-2413, ECF Dkt. 69, p 33. Only by mischaracterizing\nMs. Maxwell's argument can the government contend that she \"seeks to have this Court reach the merits of her arguments on [the Martindell] issue in the context of the civil appeal, and before they have been properly litigated before and adjudicated by the District Court in the criminal case.\" See Doc. 37, p 17. Ms. Maxwell's point",
      "position": "main"
    },
    {
      "type": "printed",
      "content": "10",
      "position": "footer"
    },
    {
      "type": "printed",
      "content": "DOJ-OGR-00019602",
      "position": "footer"
    }
  ],
  "entities": {
    "people": [
      "Ms. Maxwell",
      "Judge Preska",
      "Judge Nathan"
    ],
    "organizations": [
      "District Court"
    ],
    "locations": [],
    "dates": [
      "09/28/2020"
    ],
    "reference_numbers": [
      "Case 20-3061",
      "Document 69",
      "2940206",
      "Doc. 37",
      "No. 20-2413",
      "ECF Dkt. 69",
      "DOJ-OGR-00019602"
    ]
  },
  "additional_notes": "The document appears to be a court filing related to the case of Giuffre v. Maxwell. The text is printed and there are no visible stamps or handwritten annotations. The document is page 11 of 15."
}